Privacy Policy & Initial California Privacy Notice

Updated: 09/01/2026

OVERVIEW 

RF Renovo Management Company, LLC along with and on behalf of its subsidiary and affiliated companies (collectively “Renovo”) operates this website (the “Site”) and may make available one or more password-protected online portals, account interfaces, or related web or mobile applications, including the portal currently known as RenoVault (each, a “Portal,” and together with the Site, the “Services”) and maintains this Privacy Policy presented below (this “Privacy Policy”). This Privacy Policy applies to visitors to this website and to users of any Portal, visitors to Renovo’s offices, individuals who speak with Renovo personnel via telephone, third-party service providers, vendors and suppliers, business contacts, prospective clients, current clients, investors, employees and other Renovo personnel, borrowers, guarantors, and their authorized representatives, and any user of Renovo’s Services or services more broadly (the “End Users”). This Privacy Policy specifies how Renovo processes information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a specific individual (the “Personal Information”). 

This Privacy Policy is incorporated by reference into Renovo’s Terms and Conditions governing use of the Services (the “Terms and Conditions”). In the event of any conflict between this Privacy Policy and the Terms and Conditions with respect to the collection, use, or disclosure of Personal Information, this Privacy Policy controls. In all other respects, the Terms and Conditions control. Capitalized terms used but not defined in this Privacy Policy have the meanings given to them in the Terms and Conditions. 

The Initial California Privacy Notice required under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”) is integrated into this Privacy Policy. Renovo is providing the information in this Privacy Policy to comply with the CCPA and other applicable laws. 

Renovo’s loans are made primarily for business, commercial, or investment purposes and are not consumer credit transactions. Renovo extends the rights described in this Privacy Policy to California residents regardless of the business purpose of any lending relationship. Nothing in this Privacy Policy is an acknowledgment that any loan, account, or transaction is a consumer transaction, or modifies the representations made under the Terms and Conditions. 

INFORMATION WE COLLECT 

Renovo may collect, and has collected in the preceding 12 months, Personal Information through its website, through any Portal, or via submission of information to its employees via hard copy, email, telephone or by other electronic means. Information referred to in the Terms and Conditions as “Sensitive Information” is Personal Information for purposes of this Privacy Policy to the extent it identifies or could reasonably be linked to an individual. Such Personal Information falls in the following categories: 

Category 

Examples (not all will be collected) 

Identifier 

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol Address, email address, account name, account password, Social Security number, driver’s license number, passport number, or other similar identifiers, including multi-factor authentication credentials, device identifiers, and session identifiers used to access a Portal. 

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80 (e)) 

A name, signature, Social Security number, physical characteristics or descriptions, address, telephone number, passport number, driver’s licenses or state identification card number, insurance policy number, education, employment, employment history, bank account number, or any other financial information, taxpayer identification number, medical information or health insurance information. Some personal information included in this category may overlap with other categories. 

Protected classifications characteristics under California or Federal law 

Age (40 years or older), national origin, citizenship, marital status, medical conditions, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status. 

Commercial or financial information 

Financial records and historical financial information, investment and insurance records, or records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, and financial statements, organizational documents, insurance information, and other documentation submitted through a Portal. 

Legal and criminal records 

Information and records related to any and all prior judgments, bankruptcies, foreclosures, legal matters, alimony, child support, separate maintenance, liens filed against you or your business or other similar information. 

Internet or other similar network activity 

Browsing history, search history, information about a consumer’s interaction with a website, application or advertisement, and Portal login, access, and activity logs. 

Geolocation data 

Physical location. 

Professional, residency, or employment related information 

Current or past job history, performance evaluations, current and former state or national residency status, and real estate investment history and records. 

Education information 

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grade, transcripts, class lists, student schedules, student identification codes, and student financial information or student disciplinary records. 

Inferences drawn from other personal information 

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior attitudes, intelligence, abilities and aptitudes. 

Sensitive personal information 

Social Security, driver’s license, state identification card, or passport number; citizenship or immigration status; account log-in or financial account number in combination with any required security or access code, password, or credentials allowing access to an account; and health information. Renovo does not collect or process sensitive personal information for the purpose of inferring characteristics about an individual, and uses it only for purposes permitted under the CCPA without being subject to a right to limit. 

 

SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION 

In most cases, Renovo collects Personal Information directly from End Users. End Users will usually know when Renovo collects Personal Information because End Users will actively provide it to Renovo for a stated purpose, including by submitting it through a Portal. Renovo may also collect Personal Information from the following additional categories of sources: 

  • Service providers. 
  • Government entities. 
  • Consumer data resellers. 
  • Data analytics providers. 
  • Identity verification, bank account verification, and fraud prevention providers. 
  • Credit reporting agencies, title companies, appraisers, insurers, and other parties involved in a loan transaction. 

By its nature, Renovo’s Services may also automatically collect some Personal Information. For an End User to view or interact with Renovo’s Services, individual identifiers like IP address and some network information like date and time of pages visited is collected. Renovo may collect some Personal Information automatically using cookies or other tracking technologies, described in more detail in the cookies section below. Personal Information may be automatically collected by or on behalf of third parties who provide Renovo inferences or reporting based on analysis of such Personal Information. 

USE OF PERSONAL INFORMATION 

Renovo may use Personal Information to perform services, including maintaining or servicing accounts, providing customer service, processing or fulfilling deals or transactions, verifying customer information, processing payments, providing financing, or tracking the usage of its website or any Portal. Even if Renovo does not retain information, it still will be transmitted to servers initially and stored long enough to process. 

Renovo may also use Personal Information for the following business or commercial purposes: 

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. 
  • To give End Users information on our products and services. 
  • To provide End Users with requested information regarding Renovo’s products and services. 
  • To fulfill any other purpose for which an End User provided it. 
  • To provide End Users notices about their account. 
  • To carry out Renovo’s obligations and enforce Renovo’s rights arising from any contracts entered into between End Users and Renovo, including billing and collection. 
  • To process a request for a loan. 
  • To create, maintain, and secure an End User account. 
  • To provide support to End User inquiries by validating requestor personal information. 
  • To respond to law enforcement requests as required by applicable law, court order or governmental regulations. 
  • For research and analysis to improve Renovo’s website and or any mobile application, if applicable. 
  • To evaluate and analyze the sale or transfer of Renovo assets, including but not limited to Renovo’s servicing portfolio. 
  • For any purpose with the applicable End User’s consent. 
  • To authenticate End Users, administer multi-factor authentication, and control access to a Portal. 
  • To verify the ownership of, and information relating to, bank accounts submitted through a Portal. 
  • To investigate and respond to reports of lost, stolen, or compromised credentials and unauthorized account access. 
  • To maintain records of access to, and activity within, a Portal for security, audit, and legal compliance purposes. 

No mobile telephone numbers collected for text messaging purposes, and no consent to receive text messages, will be shared with third parties or affiliates for marketing or promotional purposes. This does not restrict Renovo from disclosing Personal Information to service providers as described below. 

HOW WE DISCLOSE PERSONAL INFORMATION 

Renovo does not sell Personal Information, and does not share Personal Information for cross-context behavioral advertising. Renovo may disclose Personal Information for the business purposes described above to the following categories of recipients: 

  • Renovo’s subsidiaries and affiliated companies. 
  • Service providers and contractors that perform functions on Renovo’s behalf, including payment processors, bank account and identity verification providers, electronic signature providers, document storage and cloud hosting providers, information technology and security providers, analytics providers, and professional advisors. 
  • Parties involved in a loan transaction, including title and escrow companies, appraisers, insurers, brokers, and settlement agents. 
  • Loan participants, note purchasers, assignees, servicers, and subservicers, and their advisors and financing sources, in connection with the sale, transfer, participation, pledge, or servicing of a loan. 
  • Credit reporting agencies and background or fraud screening providers. 
  • Attorneys, auditors, accountants, and other professional advisors. 
  • Governmental authorities, regulators, and law enforcement, where required by applicable law, court order, subpoena, or governmental regulation, or where necessary to protect Renovo’s rights or the safety of any person. 
  • An acquirer or successor in connection with a merger, acquisition, financing, reorganization, or sale of all or part of Renovo’s assets, including its servicing portfolio. 

Renovo requires its service providers and contractors to limit their use of Personal Information to the purposes for which it was disclosed and to maintain appropriate safeguards, as required by applicable law. 

Payment card numbers are submitted directly to Renovo’s payment processor and are not received or stored by Renovo. 

HOW LONG WE RETAIN PERSONAL INFORMATION 

Renovo retains Personal Information for as long as reasonably necessary for the purposes described above. Retention periods are determined by the nature of the information and the purpose for which it was collected, including the duration of the lending or business relationship, applicable statutes of limitation, contractual obligations to investors and counterparties, and legal, regulatory, tax, audit, and recordkeeping requirements. Loan and account records are generally retained for the life of the loan and for a period thereafter determined by these criteria. Where information is no longer required for any of these purposes, Renovo deletes, de-identifies, or archives it. 

INFORMATION SECURITY 

Renovo maintains administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, alteration, and disclosure, consistent with applicable law. End Users should be aware, however, that no method of transmission over the internet and no method of electronic storage is completely secure, and Renovo does not warrant or guarantee that Personal Information will be free from unauthorized access, interception, alteration, or loss. 

End Users are responsible for safeguarding their Portal credentials and devices, and for using the Portal rather than unencrypted email, text message, or voicemail to submit sensitive information, as described in the Terms and Conditions. End Users should report any suspected loss, theft, or compromise of credentials, or any unauthorized account access, promptly using the contact information below. 

Nothing in this Privacy Policy limits, waives, or disclaims any obligation of Renovo under applicable law that may not be limited, waived, or disclaimed by agreement, including any obligation to safeguard Personal Information or to provide notice of a security incident. 

COOKIES 

Through the use of cookies and similar technologies, Renovo may collect your device IP address, unique device ID, hardware and software type, Internet service provider, serving domain, geographical area, location data, browser type and settings data (such as language, screen resolution, color depth, time zone settings, browser extension and plugins) operating system, referring URLs, search history, information on actions taken or interaction with our digital assets (e.g., page views, x/y coordinates of mouse events) and dates and times of actions. 

The types of cookies Renovo may use include Google Analytics to collect information about how End Users use Renovo’s website. Renovo may use this information to create reports and improve its website. The cookies help Renovo understand the number of visitors to its website and where visitors come from. To opt-out from these cookies across all websites, visit http://tools.google.com/dlpage/gaoptout. 

Many web browsers allow individuals to manage cookies through their browser settings. Be aware that, opting-out from and not agreeing to certain cookies may diminish an End User’s experience on Renovo’s website and some features may not work as intended depending on the cookie. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org. Please note that opting-out of cookies, tags, and pixels only pertains to the device and the browser that you are using when you opt-out. Cookies and similar technologies are not used to authenticate access to a Portal in place of credentials. 

IMPORTANT RIGHTS REGARDING PERSONAL INFORMATION 

Where applicable, End Users who are California residents have the following rights under the CCPA in relation to Personal Information collected as defined in the CCPA; these rights are granted to the extent required by the CCPA and are subject to verification and any applicable exceptions: 

  • Eligible End Users have a right to know about Personal Information collected, used, disclosed, or sold by Renovo. 
  • Eligible End Users have a right to know about Renovo’s practices regarding the disclosure or sale of Personal Information. Please note that Renovo does not sell Personal Information. 
  • Eligible End Users have a right to request deletion of Personal Information. 
  • Eligible End Users have a right to opt-out of the sale of Personal Information. However, as noted, Renovo does not engage in the sale of Personal Information. 
  • Eligible End Users have a right not to receive discriminatory treatment by Renovo for the exercise of the privacy rights conferred by the CCPA. 
  • Eligible End Users have a right to request correction of inaccurate Personal Information maintained by Renovo. 
  • Eligible End Users have a right to opt out of the sharing of Personal Information for cross-context behavioral advertising. As noted, Renovo does not share Personal Information for that purpose. 

Residents of states other than California may have rights regarding Personal Information under applicable state privacy laws. Renovo will honor those rights to the extent, and in the manner, required by applicable law. To exercise any such right, or to ask whether a particular right is available to you, please use the contact methods below. 

To exercise or inquire about any of the rights described above, or to submit any inquiries or express any concerns about Renovo’s privacy policies and practices, please contact Renovo by e-mailing us at legal-compliance@renovofinancial.com.

Renovo will need to verify the identity of any person making such a request or exercising the rights described above. The End User submitting a request or exercising one of the rights above must provide enough information to verify their identity and address, and a description of what right they wish to exercise along with any information to which their request relates. Only the End User, or someone legally authorized to act on the End User’s behalf, may make a verifiable request related to Personal Information collected about a specific End User. To designate an authorized agent, the authorized agent must provide sufficient information that allows Renovo to reasonably verify that they have been authorized by the relevant End User to act on their behalf. For requests which could lead to the potential disclosure or deletion of sensitive information about an End User, for instance a social security number, Renovo may require a heightened level of verification. 

A request submitted through a Portal, or from the email address associated with a Portal account, does not by itself satisfy these verification requirements. Renovo may decline a request it cannot verify. 

LINKS TO THIRD-PARTY WEBSITES 

Renovo’s Services may contain links to third party websites which, in some cases, may be integrated into, and appear to be part of, Renovo’s Services. Renovo encourages all End Users to read the privacy policies of other websites and disclaims any responsibility for the privacy policies and procedures of any third-party websites that End Users reach via a hyperlink contained on Renovo’s Services. Such hyperlinks are provided for your convenience only, and you access them at your own risk. 

CHILDREN’S PERSONAL INFORMATION 

Renovo’s Services are not intended for or targeted towards, and Renovo does not knowingly collect Personal Information via the Services from, children under 18 years of age. 

UPDATES TO THIS PRIVACY POLICY 

Renovo reserves the right in its sole discretion to modify or amend this Privacy Policy in any way at any time. Any such changes are effective upon posting and we will indicate in the Privacy Policy when it was most recently updated. Users of Renovo’s Services should review this Privacy Policy periodically for any applicable changes. Additionally, note that by accessing Renovo’s Services subsequent to any modification, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended. 

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